Perpetual Registration, an Annual Fee and 31 January 2027: The Notified Intermediaries Amendment Compliance Clock

The IRDAI (Insurance Intermediaries) (Amendment) Regulations, 2026 were notified on 31 July 2026, three days after the regulator's 137th Authority Meeting on 28 July approved the package. This is not a single-entity change. One instrument amends five sets of registration regulations at once: the Registration of Corporate Agents Regulations, 2015, the Insurance Brokers Regulations, 2018, the Insurance Marketing Firm Regulations, 2015, the Insurance Web Aggregators Regulations, 2017 and the Common Public Service Centre Regulations, 2019. Every distribution entity registered under any of them is inside the perimeter.

The headline change converts the three-year certificate of registration into a perpetual one. Under the notified text, a certificate once issued remains valid subject to payment of a non-refundable annual fee, and continues until it is suspended, cancelled or surrendered. The renewal application every three years is gone; an annual fee and continuous compliance take its place.

But the notification is not only about registration mechanics. It also brings in mandatory tagging of the authorised salesperson to every proposal form, policy and certificate from 1 January 2027, a deemed no-objection certificate after 30 days of employer silence, and a Letter of Enrolment for salespersons alongside the retained NOC requirement. For a distribution business, the next six months are governed by two dates: 1 January 2027 for document tagging and 31 January 2027 for the fresh-certificate application. Both require build work, not just a filing.

This post covers the notified regulations in operational terms. For the statutory shift that preceded it, the Sabka Bima Act's move to perpetual licences from February 2026, see the compliance model that replaces the renewal cycle.

The perpetual certificate is paid for annually. The fee is the higher of INR 10,000 or 0.04 percent of commission and other receipts received from insurers during the preceding financial year, and it is non-refundable.

The arithmetic is worth doing before budgeting, because the two limbs of the formula cross at a specific point. At 0.04 percent, a firm pays more than the INR 10,000 floor once its commission and other receipts from insurers exceed INR 2.5 crore in the preceding year. Below that line, every entity pays the flat INR 10,000. Above it, the fee scales with the book:

• A corporate agent or IMF with INR 2 crore of insurer receipts pays the floor, INR 10,000.
• A mid-tier broker with INR 25 crore of commission income pays INR 1 lakh.
• A large broker with INR 250 crore of commission and other receipts pays INR 10 lakh.

Two drafting details matter more than the rate. First, the base is commission and other receipts received from insurers, not brokerage alone. Reward, remuneration and other insurer-paid amounts sit in the base, so the fee computation should start from the firm's full insurer-receipts ledger, reconciled to what insurers report on their side, not from the commission line in the management accounts. Second, the base year is the preceding financial year, which means the fee for a given year is computable the moment the prior year's books close, and finance can put it on the compliance calendar with certainty rather than estimating.

Against the old regime, the cash cost is modest: even at INR 10 lakh a year for a very large broker, the fee replaces the three-yearly renewal exercise and its internal preparation cost. The real change is character, not quantum. A missed renewal used to be an application problem; a missed annual fee under the new text is non-payment of the condition on which the certificate's continuing validity rests.

Perpetual registration does not flow automatically to entities holding a live three-year certificate. Every existing intermediary must apply for a fresh certificate of registration by 31 January 2027. Those that miss the date get a grace window: applications are accepted until 31 March 2027, but only with reasons for the delay and an additional fee of INR 750.

Read the two dates the way the regulator has structured them. The INR 750 additional fee is trivial; the requirement to state reasons for delay is not. A regulated entity opening its perpetual-registration file with a written admission that it missed a six-month statutory window is handing its supervisor a data point about its compliance function, at the moment it is deciding whether to issue the fresh certificate. The late window exists to prevent accidental lapses from becoming existential; it is not a second deadline to plan around.

The practical work between now and January is assembling a clean application file, and the discipline looks like the old renewal file done once more, properly:

1. Reconcile the register of directors, key managerial persons and shareholding against every intimation actually filed with IRDAI, and cure gaps before applying rather than inside the application.
2. Confirm net worth, professional indemnity cover and principal officer qualifications are current and evidenced, since these are the standing conditions the fresh certificate will carry forward.
3. Compute the first annual fee from the preceding year's insurer receipts and have the payment mechanics agreed with finance.
4. Close out pending IRDAI correspondence and grievance items so the file the regulator sees is not carrying open threads.

The second clock is shorter and touches documents rather than registrations. From 1 January 2027, every proposal form, insurance policy and insurance certificate must carry the name and functional identification of the authorised salesperson who solicited or sold the policy, along with the mobile number and email address of the branch or office through which the policy was sourced. The 137th Authority Meeting's stated purpose is accountability, traceability and transparency: a policyholder holding any issued document can see exactly who sold it and which office stands behind it.

Where a policy is bought directly through an intermediary's digital platform with no authorised salesperson involved, the documents must instead display the contact details of the intermediary's Principal Officer. That default is worth pausing on. A web aggregator or a broker's direct-to-customer journey cannot simply leave the salesperson field blank; the Principal Officer's name and contact details go on every digitally sourced policy. Principal Officers of digital-heavy distributors should expect their details to appear on tens of thousands of documents and plan the inbound-contact handling that follows, because a customer-facing phone number printed on a policy will be used.

For sales through people, the requirement forces a data question most distributors have never had to answer at issuance time: which specific authorised person sourced this policy, under what functional identification, from which branch? Today that mapping often lives informally in CRM ownership fields, sub-broker codes or branch spreadsheets, and it is cleaned up later for commission allocation. From January it must be correct at the moment the proposal form is generated, because it prints onto the document the customer receives.

A certificate of insurance issued under a group or master policy is inside the scope too. Distributors running high-volume certificate issuance, travel, transit, affinity and lender-linked business, should check that their certificate-generation pipelines can carry the tagging fields, not just their policy-issuance flows.

Alongside the document tagging, the amendments rework how salespersons move between distributors. IRDAI has introduced a Letter of Enrolment for salespersons while retaining the no-objection certificate requirement from the existing employer. The operative change is a deadline: if the existing employer neither issues the NOC nor communicates an objection within 30 days, the NOC is deemed to have been granted. Similar deemed provisions apply to authorised verifiers of telemarketers and to intermediaries themselves.

The old dynamic this ends is familiar to anyone who has run distribution hiring. An employer that did not want to lose a productive salesperson, or wanted to pressure recovery of advances or training costs, could simply sit on the NOC request indefinitely. The salesperson could not lawfully solicit for the new firm, and the hiring firm could not complete enrolment. Silence was a veto. From now on, silence for 30 days is consent.

Both sides of the hiring market should adjust:

• As the hiring firm: date-stamp the NOC request, diarise day 30, and document the deemed grant before activating the salesperson. The deemed NOC is only as good as the evidence that the request was made and 30 days passed without objection, so send requests through a channel that proves delivery.
• As the losing firm: an objection now has to be an actual, communicated objection within 30 days, on grounds the firm is prepared to stand behind. Genuine disputes, unrecovered advances, pending misconduct inquiries, must be raised inside the window or the person walks with a deemed NOC. Build a triage step so every incoming NOC request gets a decision within a fixed internal deadline well short of 30 days.

IRDAI's response to public comments also clarified a point that had worried training functions: removing Authority-issued certification for Specified Persons does not change the training, examination and qualification requirements themselves. The competence bar stays where it was; what changes is the paperwork that evidences it and the speed at which a qualified person can move. Expect attrition cycles at large corporate agents and broking branches to compress, because the friction that slowed poaching has a statutory expiry date on it.

For a broking house or corporate agent, January's tagging requirement is a systems change wearing a compliance label. The build has three layers, and each has a lead time that makes August the right month to start.

Salesperson master data. The firm needs a single authoritative register mapping every authorised salesperson to a functional identification, a branch, and that branch's designated mobile number and email address. Most firms have fragments of this across HR, training records and CRM user tables. The register must also handle the awkward cases: a salesperson who moves branches mid-policy, a policy sourced jointly, a renewal where the original salesperson has left. Decide the rules now and encode them, because the document generated in January will print whatever the data says.

Proposal and policy templates. Every proposal form template the firm generates needs new fields, and every certificate format issued under delegated authority needs the same. For the digital journeys, templates need the Principal Officer fallback wired in as the default when no salesperson is attached. Template changes at insurers move slowly, which leads to the third layer.

Insurer data feeds. The policy and certificate are issued by the insurer, so the salesperson tag has to travel from the intermediary's CRM into the insurer's issuance system. That means agreeing field definitions, adding the tagging data to placement slips and proposal data feeds, and testing that what the insurer prints matches what the broker sent. A broking house placing business with 25 insurers has 25 integration conversations to have before December, alongside every other distributor asking for the same change.

The same programme should fold in the disclosure changes moving through the wider amendment package, covered in what the 2026 intermediary amendments change on disclosure, so the templates are opened once, not twice.

The conversion deadline is usually discussed as the intermediary's problem. Corporate insurance buyers should read it as theirs too, because a broker that fails to convert cleanly stops being able to act.

A certificate of registration is the legal basis on which a broker solicits, places and services business. An intermediary that neither applies by 31 January 2027 nor uses the late window to 31 March 2027 is heading toward a registration that no longer supports its operations. For a corporate client, the failure modes are concrete: a renewal falling due while the broker's status is unresolved, claims advocacy passing to a firm that cannot formally represent the client to insurers, and open market placements mid-slip with a broker insurers may decline to deal with. Placements themselves do not vanish, the policies are contracts with the insurer and remain valid, but the client loses its intermediary's mandate at exactly the moments it is most needed.

Risk managers and CFOs should therefore put one question into every broker review between now and Q4: confirm the status of your fresh-certificate application under the Insurance Intermediaries (Amendment) Regulations, 2026, and your readiness for salesperson tagging from 1 January 2027. A broker with a good answer will name its application date, its programme owner and its insurer-feed test plan. A vague answer in October is a reason to think about contingency before a January renewal, not after.

The direction of the whole package matches the wider statutory reform: the Sabka Bima Act's intermediary provisions removed the periodic re-grant, and these notified regulations supply the machinery that replaces it, an annual fee, a one-time conversion, and person-level accountability printed on every document. Corporate agents face the same conversion mechanics through their own amended 2015 regulations, covered in the corporate agent norms update. The registration is perpetual; the compliance is now annual, continuous and visible to every policyholder who reads their policy.